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In our comment letter, we support the PCAOB’s efforts to revise its quality control standards and agree that the PCAOB should follow the risk-based approach to quality management the International Auditing and Assurance Standards Board (IAASB) has proposed in International Standard on Quality Management (ISQM) 1. Also, we support the requirement for firms to make an annual evaluation about the effectiveness of their system of quality control. However, instead of requiring firms to report to the Board or to publicly report about their annual evaluation, we believe the PCAOB should require firms to communicate information about their annual evaluation to the audit committee of each of the issuers they serve. We also believe an extended implementation period is necessary to give firms sufficient time to design and implement an effective system of quality control that complies with any final standard.
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